Conducting an Independent Anti-Money Laundering (AML) Program Audit

OPPORTUNITY

A mutual fund complex and an affiliated registered broker-dealer needed to conduct an annual independent AML program audit to satisfy regulatory requirements set forth by the USA PATRIOT ACT and FINRA Rule 3310.

The firm had delegated significant tactical responsibilities to outside parties, thereby necessitating an evaluation of both firm oversight and third-party reporting.

PROCESS

We identified areas of particular operational or regulatory concern, and reviewed and tested the design adequacy and operational effectiveness of the joint-AML program, surveillance practices delegated to third parties, related training, and required documentation. Each review culminated in an oral presentation to executive management and a written report to the mutual funds’ board of directors.

RESULTS

ReGroup continues to conduct independent audits of the client’s joint-AML program while providing fresh insights and thoughtful recommendations on a year-over-year basis. The AML program’s ongoing evolution demonstrates continuous improvement to the mutual funds’ Board of Directors.